A motion filed Tuesday in Leavitt's wrongful termination suit attempts to connect his firing in January to USF's signing of basketball transfer Gus Gilchrist 18 months earlier, alleging that athletic director Doug Woolard twice in summer 2009 (it's intended to be 2008) "personally confided" to Leavitt that USF had to find a job for Gilchrist's trainer, Terrelle Woody, as a "quid pro quo" to sign the transfer, and that Woolard knew doing so would likely violate NCAA rules.

Woody worked two seasons as a strength and video assistant on coach Stan Heath's staff, but the NCAA reviewed the matter and found no wrongdoing in his hiring; the practice of hiring a close associate or relative of a recruit before or after his or her signing has since been disallowed by NCAA by-laws. USF coach Stan Heath has been adamant that Gilchrist signed with USF regardless of Woody's hiring two months later.

The motion filed Tuesday by attorney Wil Florin in Hillsborough County Circuit Court includes a previously submitted "request for admissions" from USF, which asserts that Leavitt advised Woolard not to hire Woody, citing an instance where Leavitt was presented a similar situation with a recruit from Miami. Woolard "was willing to risk violating NCAA recruiting rules in 2009 (sic) in order to strengthen the competitiveness of the USF basketball team," according to Leavitt's attorneys, and knew that "Gilchrist would not attend USF absent USF employing his close friend Terrell (sic) Woody."

The motion also alleges that Woolard did not disclose his conversations with Leavitt to the NCAA when they reviewed Woody's employment last fall, and that it was with those conversations in mind that Woolard "had a pre-determined mindset to terminate" Leavitt "in order that Leavitt be publically (sic) discredited in the event Leavitt was questioned regarding his knowledge of the basketball recruiting issue and thereby protect Woolard's reputation and job security at USF and any future employment."

USF's legal response denies that the Woolard-Leavitt conversation took place and "denies that Leavitt ever rendered such advice; in fact, Doug Woolard had to caution Leavitt not to hire the father of a high school football player as part of a package deal when Leavitt was attempting to recruit the son."

The 55 requests for admissions from Leavitt's attorneys, most of which were denied in response by USF, have very little to do with the incident that led to Leavitt's firing -- he was found to have grabbed player Joel Miller by the throat and slapped him twice during halftime of USF's Nov. 21 game against Louisville -- and more to do with the procedural aspects of his firing and the investigation that led to USF's decision.

"It's a puzzling strategy. It feels to me like a desperate strategy," USF spokesman Michael Hoad said. "They're attempting to make a big deal of a small part of the legal process. A lot of this digging up old stories like Terrelle Woody, this case isn't about that. In the end, a jury is going to decide who is telling the truth. I don't think a lot of this is going to make a lot of difference in that."

Other details of what Leavitt's attorneys are seeking to establish through this motion:

-- Using a statement given by USF administrator Glen Besterfield to investigators that USF President Judy Genshaft had said the only things that can take down a college president are "docs and jocks," the attorneys assert that Genshaft had "a pre-determined mindset to terminate Coach Leavitt regardless of the facts gathered in the investigation in order to protect her own position and job security at USF." USF's response states that Genshaft's quote was not made in reference to the investigation or firing, and actually supports "the inverse of the asserted proposition."

-- They asserted that USF vice president Sandy Lovins, whose notes did not include the "docs and jocks" comment while attorney Thomas Gonzalez's notes did, "intentionally omitted" the comment from her notes "in order to protect Genshaft from an obvious appearance of having reached a pre-determined conclusion to terminate Coach Leavitt regardless of facts uncovered." USF's response states that "the statement did not register with (Lovins) because it had no relevance to the investigation."

-- In response to the requests for admission, USF's attorneys admit that Woolard does use a "personal digital assistant device or personal cellular telephone" as part of his job, and that Genshaft "corresponded" with others about the investigation at times using a personal cellphone. Leavitt's attorneys are seeking to have archived e-mails and text messages from the phones during the investigation and search for a new coach admitted as public records.

-- Leavitt's attorneys asked USF to "admit that the integrity of the USF review process was compromised by USF's intentional decision to not fully record or transcribe all witness interviews through us of a court reporter and by USF intentionally failing to have the review conducted by individuals independent of USF and President Genshaft." In response, USF wrote that "the integrity ... was not compromised."

-- Leavitt's attorneys, questioning how "independent" Gonzalez was in co-chairing the investigation, asked USF for a list of all matters in which his firm has represented USF or provided legal services. The list supplied by USF includes more than 20 cases totaling $328,664 since 1996. USF's response states that interpreting an "independent process" to mean "independent of USF" is a "mischaracterization."

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